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Accessibility & Procurement: What do we need to know?https://wcetfrontiers.org/2018/11/14/accessibility-procurement-what-do-we-need-to-know/
https://wcetfrontiers.org/2018/11/14/accessibility-procurement-what-do-we-need-to-know/#respondWed, 14 Nov 2018 14:00:03 +0000http://wcetfrontiers.org/?p=10590WCET and the Online Learning Consortium (OLC) jointly offer this blog post on a topic of national interest to education communities. This post is part of the on-going collaboration on accessibility issues between WCET and OLC.

Thank you to Kelly Hermann, University of Phoenix, for today’s guest post on these important issues!

It often feels like there are many more questions about accessibility than there are answers. This is especially true when it comes to deciding which content, tools and/or products we are going to bring to campus and use in our courses. Cyndi Rowland wrote a great piece about “The Role of Procurement in Digital Accessibility” right before the WCET annual meeting. Since we are about to gather together in Orlando for OLC’s Accelerate conference where we will have a featured session on this topic, I want to take a step back and walk through questions I think campus administrators have to ask themselves about the product/tools/content we use and how we choose them.

I think it has become clear by now that the ADA and Section 504 requires colleges and universities to ensure that its digital environments and activities are accessible to individuals with disabilities as an aspect of each law’s provisions prohibiting discrimination on the basis of a disability. What this means is that everything we do online is—in some way, shape or form—a service offering or activity of the institution and must be accessible.

It is also an opportunity for us to remind ourselves not to be penny wise and pound foolish. As Cyndi mentioned in her post, the federal government has reminded us that there are certain accessibility needs that we know will need to be addressed (e.g., captions) regardless of when, how or why a person with a disability requests it. It benefits all of us to “bake” this level of accessibility into our activities rather than wait to “bolt” it on after the fact.

What does it mean to “bolt on” accessibility?

Let’s take a look at this picture of a building entrance. What do you notice about it?

The first thing I notice is that the ramp was not part of the original design. The ramp is red, metal, and temporary and covers over several steps to the entrance. The ramp doesn’t fit in, so it sticks out like a sore thumb. This is what I would refer to as “bolted on” accessibility. It is a modification made after the environment was built to address an access need because an individual with a disability could not enter the building without it. It is an afterthought and was retrofitted.

What does it mean to “bake in” accessibility?

In contrast, the ramp is a universally-designed component that fits with the design and the aesthetic of the building.

This ramp is an example of “baking” accessibility into your design. This ramp serves as a means for individuals with disabilities to access the building but, unlike an elevator, is still available in the event of an emergency requiring people to evacuate the building quickly. There was no need to retrofit accessibility into this building. The ramp provides a welcoming, inclusive environment for guests of all ability levels.

We can accomplish the same thing in our digital environments when we consider accessibility during all phases of content development, both for our websites and online courses. The stakes are a little higher for online courses, so let’s focus on the questions you and your content developers (faculty, subject matter experts, instructional designers, academic administration, educational technologists, etc.) should be asking as you are deciding what to include in your courses.

What is this tool, product, or content going to be used for?

My academic colleagues are sometimes surprised when the first question I ask when reviewing a course for accessibility is to have them walk me through the learning objectives for the course. Why? Because the learning objectives are really at the heart of determining which components are or are not a reduction of standards or a fundamental alteration of the course, assignment, or program. This is important not only for determining reasonable accommodations in the disability services office but also for deciding whether or not the selected tool/product/content is integral to the course when it is not accessible.

This question also addresses one of the myths that seems to pervade higher education’s understanding of accessibility requirements. I am frequently asked this question, “Kelly, why are we prioritizing the needs of a few students over the needs of the many?” At face value, the question can be infuriating to those of us who work with students with disabilities and realize that they deserve the same care and consideration as every other student in the class. But that usually isn’t the message the person is attempting to convey. Some people may feel like we are playing a zero-sum game when this is not the case, and it can seem like ADA/504 concerns are taking away our ability to be creative, innovative and agile.

The reality is exactly the opposite. Designing with accessibility in mind and addressing accessibility concerns long before a student ever enters a course allows us to be more creative and to think outside of the box to find solutions. It also allows us to build in support for all students at the university, not just those with identified or disclosed disabilities.

Let’s take captions for instance. Most of us know that individuals who cannot hear will need a text-based alternative for the sounds of a video. What we might not realize is that captions benefit the student who needs to watch a video for class during his/her lunch hour and forgot to bring headphones to work. That student can now watch the video, with the sound off and the captions on, and still consume the content of that video by reading the captions. Or how about students who speak English as a second language? Captions are a great tool for them to use to reinforce their understanding of the English language as they can listen and read at the same time. And there are lots of other examples. The point is that captions benefit more users than the ones for which they were originally designed. The result is that the video is not only more accessible, but more usable as well.

Who are our students?

This may seem like a no-brainer—of course we know who our students are. But do we really? Do you know which students are enrolling in your online courses and what background and experiences they are bringing with them? This is especially important when considering your students with disabilities on campus.

At the University of Phoenix, we focus on adult learners. Adult learners tend to have multiple, competing responsibilities they are balancing with their school work, including jobs, families, volunteer commitments, etc. And adult students with disabilities are more likely to have acquired their disability after their last formal experience with schooling and have very limited experience with asking for and using accommodations, including assistive technology. I have worked with thousands of students over the past 13 years at two different adult-learner focused institutions with strong online programs and have found this to be true.

Many of these students are learning how to use the assistive technology at the same time that they are enrolling in online courses and learning your content. That is a lot to grasp at one time. These students may not be savvy users of technology and may require your disability services office to recommend different accommodation strategies for them.

In addition to knowing where your students reside on the traditional vs. non-traditional spectrum, it is also important to understand what disabilities are disclosed to your disability services office and at what rate. It used to be a fairly safe bet that schools with traditionally-aged population of students would have a large number of students with learning disabilities. In recent years, we have seen a shift and now more students are disclosing mental health and psychological diagnoses. And as medical advancements have evolved, more and more students are coming to us with chronic and sometimes episodic medical conditions. These students may be looking at your online courses as a way to progress towards their degrees in light of the challenges they face in traveling to campus. What does accessibility look like for them?

Are there alternative means to teach this content to students?

I think we sometimes forget that we were teaching math to college students long before the publishers decided to put together software programs and websites to supplement their textbook materials. How did we do that? We need to get back to some of those basics when the desired tools we want to use do not meet our accessibility standards.

Cyndi’s post laid out the essential steps that all institutions should consider when working with vendors throughout the procurement process. Those are critical. But what happens when the tool that you want to use in your course is not accessible, yet it is essential to the learning objectives of the course? This is a conflict that I am asked about frequently, both at my own institution and by colleagues at other institutions. Let’s break it down.

First, we need to determine if the selected tool is truly essential to the learning objectives of the course. Let’s say that I am reviewing an accounting course. It is an introductory level course that is designed to teach students the basic principles of accounting. The instructional designer has worked with the subject matter expert, a tenured accounting professor, and has determined that the assignments should be built around a specific accounting software that is both commercially available and widely used by accountants and small business owners. However, that particular tool does not meet the university’s benchmark accessibility standard. I present my report to the instructional designer, the subject matter expert, and the dean responsible for the course. We know that the learning objectives are focused on accounting principles and not on mastery of this particular tool, so it appears that we can substitute this tool with another means of demonstrating learning.

The next things we look at are the assignments themselves. What exactly are students required to do? We want to be sure that we are providing students with the right tools and instructions, so they can effectively demonstrate that they have met the learning objectives. If the assignment is to determine the profits and losses for a small company in a particular month, does that task have to be performed with that specific tool, or are there other ways to accomplish it? Can those tasks be performed in a spreadsheet program that is accessible? Does it make sense to offer all students the option to choose one of multiple methods for completing the assignment rather than just requiring the one program that is not accessible?

Many of you might be scratching your heads right now and thinking, “Kelly, it almost sounds like you are saying that it is ok for us to use inaccessible tools in our courses if we have an alternative?” This is one of those statements where colleagues usually accuse those of us in accessibility and disability services as being an “all or nothing” type entity, and we aren’t.

There are times when it is absolutely essential to include inaccessible content, but that doesn’t mean that you don’t have to be proactive. You have to have an equally effective alternative for that assignment that offers the student with a disability the opportunity to demonstrate what they have learned in a manner that allows them to be independent with “substantially equivalent ease of use” (FAQ about the June 29, 2010 Dear Colleague Letter, 2011).

This is a good opportunity to remind everyone what the Office for Civil Rights and the Department of Justice have said the definition of accessibility is:

Students with disabilities “must be afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services” as students without disabilities “with substantially equivalent ease of use” (Joint Dear Colleague Letter, June 2010).

This does not mean that we arbitrarily say that tools that we want to use are vital to the course—regardless of their accessibility—and that the institution will just pay for a reader to work with a student who can’t access said tool. That solution does not allow the student to acquire the same information, with the same interactions, and with the same service allowing substantially equivalent ease of use, and it is not a good experience for the student who needs that access. But it does mean that we have to be reasonable when balancing the needs of the students with the learning objectives of the course or program.

To go back to our accounting course example, I would argue that the specific program that does not meet the university’s accessibility standard is not essential to the learning objectives of the introductory accounting course. Now, if the course we were reviewing was “Accounting Software for the Small Business Professional,” and a learning objective of the course was not only to gain mastery of the program, but to also pass a certification exam for use of that program, then the program is essential to the learning objectives of the course, and we need to develop an alternative access plan for any student who enrolls in the course and cannot use the program.

Bringing it all together: the recipe for access

Cyndi’s post highlighted the responsibility that institutions have, not only for buying accessible tools, but also for ensuring that we protect our institutional resources by asking about accessibility, obtaining accessibility documentation about desired products and services, and including language in our contracts regarding the promised accessibility standards when procuring external content. These steps are critically important have had considerable impact on the tools that our institutions are using today. We need to ask vendors how they address accessibility, what their accessibility roadmap is, what sort of user-acceptance testing they do with screen readers and other assistive technology, and how we can share feedback regarding accessibility throughout all stages of the relationship between the vendor and the institution.

We also need to be sure that our colleagues understand what accessibility is and what it isn’t. Many of the resolution agreements related to web accessibility signed with the Office for Civil Rights include requirements for campus-wide training on accessibility. We need to be sure that we stock our colleagues’ toolboxes when it comes to accessibility. Because accessibility is an institutional responsibility, not just the responsibility of your disability services office. We all have a part to play in building a culture of accessibility on campus, baking accessibility into everything we do, and ensuring that students feel welcomed and included, regardless of their abilities, so they can earn their degrees and attain their goals.

]]>https://wcetfrontiers.org/2018/11/14/accessibility-procurement-what-do-we-need-to-know/feed/0quote 1linsraedownsA wheelchair ramp over several stairs.SEveral sets of stairs with a ramp built into the stairway, instead of placed over it (retrofitted)quote box: Adult students with disabilities are more likely to have acquired their disability after their last formal experience with schooling and have very limited experience with requesting and using accommodations, including assistive technology.author headshotCC LogoIs this the Future? The Education Department’s Higher Education Ecosystem Challengehttps://wcetfrontiers.org/2018/11/09/departments-higher-ed-ecosystem-challenge/
https://wcetfrontiers.org/2018/11/09/departments-higher-ed-ecosystem-challenge/#respondFri, 09 Nov 2018 17:51:29 +0000http://wcetfrontiers.org/?p=10568Recently, the U.S. Department of Education announced their winners of the Department’s Higher Education Ecosystem Challenge. The challenge was to “imagine what higher education would look like in 2030.”

WCET’s Dan Silverman, Assistant Director of the WCET State Authorization Network (SAN), attended the event honoring the 10 winners of this year’s challenge. Today he joins us to report on the event and provide his thoughts on these projects.

The challenge attracted 164 entries, and the 10 winners received the opportunity to pitch their ideas to funders and possibly to receive unspecified, non-monetary support from the Department.

Post-Secondary education as a lifelong, career-focused pursuit

U.S. Secretary of Education Betsy DeVos and Marcia McNair, president of the National Academy of Sciences, gave opening remarks that set the tone: the rapidly changing labor market, automation, and desire for meaningful work means that post-secondary educational institutions must be willing to start from scratch in order to serve lifelong learners in career-focused ways.

Before the ten winners had their chance to give three-minute pitches to the assembly, Sharon Leu, senior policy advisor at the Department and emcee of the program, summarized trends she saw across the submissions.

She noted that many of the submissions were partnerships working together to serve populations that are hard to reach, such as the incarcerated. She also observed that the submissions focused on post-secondary education as a lifelong activity, not as a box to check once. Finally, she reported that collaborations—rather than single institutions—will emerge as foundations of the higher education ecosystem of the future.

Lue presented at the WCET Annual Meeting where she expanded on some of these ideas. She was joined by one of the winners, Wayne Skipper of Concentric Sky. Along with their partners, BrightHive and the DXtera Institute, Concentric Sky’s winning proposal “responded to the challenge with a vision for a future designed around decentralized, fully portable, vendor-agnostic, self-sovereign student records.”

And the winners are...

Only a few of the winners, such as Southern New Hampshire University and Paul Quinn College, came from degree granting institutions, and even those schools won for non-degree granting programs. Representatives from degree granting schools made up a minority of the audience as well; venture capitalists, ed tech entrepreneurs, foundations, and other firms composed most of the crowd.

One question this raises is how—if at all–traditional higher education institutions are reacting to these sorts of initiatives. And while these alternative credentialing programs operate mostly outside the traditional financial aid ecosystem, it is a possibility that federal regulatory reform could allow federal financial aid to flow in those directions at some point.

Some of the winning projects focused on the provision of specific, employment-centered alternative credentials for working adults at all stages of their careers. The Google IT Support Professional Certificate, for example, is a five course sequence on Coursera that prepares learners for entry level degrees in IT. Another popular concept was the opportunity for learners to earn stackable and competency-based accomplishments that employers could value and trust. FlexchainEDU and EdRec are two projects trying to empower learners in this way, throughout their careers.

Although the majority of the winners of this particular challenge focused on new methods to teach students very specific and employer-focused skills, DeVos and McNair’s framing of the challenges facing post-secondary education raise the possibility that adaptation is an essential skill as well. It will be interesting to see what innovations emerge to meet the challenge of acquiring more abstract—and difficult to assess—skills.

]]>https://wcetfrontiers.org/2018/11/09/departments-higher-ed-ecosystem-challenge/feed/0quotelinsraedownsphoto of the US Capitol Buildingwinners of the edu2030 ecosystem challenge in a listdan silverman headshotCC LogoThe Benefits and Challenges of Course Learning Outcome Assessment in Every Course Every Termhttps://wcetfrontiers.org/2018/11/07/learning-outcome-assessment-ecet/
https://wcetfrontiers.org/2018/11/07/learning-outcome-assessment-ecet/#commentsWed, 07 Nov 2018 13:08:21 +0000http://wcetfrontiers.org/?p=10543How does your college or program handle learning outcome assessments? Today we’re thrilled to be joined by several representatives from the University of Western States, Bernadette Howlett, Denise Dallmann, Dana Sims-Barbarick, and Susan Donoff, to discuss the University’s Every Course Every Term (ECET) initiative. This continuous improvement program helps faculty collect and act on course learning outcome data. Read on to learn more about this great initiative and their lessons learned, in case you’re interested in developing a similar program.

Thank you to Bernadette, Denise, Dana, and Susan for sharing this program with us!

Enjoy the read and enjoy your day,

Lindsey Downs, WCET

Questions regarding the quality and value of a college education are stimulating calls for accountability through measures of student outcomes. Much of this attention has been focused on graduation rates, loan repayment, debt burden, and gainful employment. And, as WCET has recently reported, the federal government is preparing to alter the regulations that govern higher education accreditation. Among other changes the Department of Education is considering is to increase the emphasis on outcomes (degrees conferred, licensure exam results, etc.) for purposes of determining access to Title IV funding. While metrics associated with graduation and employment offer high-level perspectives on how institutions and programs perform, they have two important limitations:

There is no opportunity to intervene for individual students by the time they experience the outcome; and,

The measures are one-dimensional.

Most institutions engage in robust assessment processes focused on measurement of mission and goals (or Core Themes for those accredited by the Northwest Commission on Colleges and Universities) attainment as part of their self-assessment of quality.

Institutions collect a variety of focused indicators of students’ performance and progress at multiple levels as represented in Figure 1.

Though there is debate about the impact of learning outcome assessment, one of the most useful quality indicators can be course learning outcome assessment data, because it enables early intervention and continuous course and program improvement.

Every Course Every Term (ECET)

In order to utilize early performance data about students and programs as part of its self-assessment system, University of Western States (UWS) in Portland, Oregon, has undertaken a bold continuous improvement initiative to collect and act on course learning outcome (CLO) data every time each course is offered. This initiative is called “Every Course Every Term, or ECET.”

After a successful pilot phase, UWS launched its ECET initiative in the summer term of 2018. The cycle for the process, represented in Figure 2, utilizes a rapid instructional design system. Each course proceeds through a three-step process:

mapping CLOs in the Learning Management System (LMS) to their corresponding assessments and teaching the course;

extracting and analyzing the CLO data from the LMS; and,

initiating course improvements based on that analysis.

The process is then repeated and documented in a course ECET report that is used to track attainment of student learning outcomes over time.

The data are used to inform revisions at multiple levels: course design/outcomes, assessments, program design/outcomes, admissions requirements, policies, identify professional development opportunities, and more. UWS faculty and staff initiated greater frequency of CLO review than the common practice of once every few offerings due to a strong interest in continuous improvement to support student success.

Student success and teaching excellence are central values to the institution. As articulated by Dr. Denise Dallmann (Dean, Center for Teaching and Learning):

“We always come back to the mission.” The mission of UWS is to advance the science and art of integrated health care through excellence in education and patient care. Further, the university’s first Core Theme is Student Success. “Excellence in education is really about continuous improvement and doing everything we can to support student achievement of learning outcomes.”

The Project

UWS anticipates it will take three academic years to “onboard” every course to this project.

The plan is to include an additional 10 courses per term (two per program) for a total of 120 courses, including all electives. Not every course is offered every term, but by the end of the three-year onboarding period, all courses will be in one of the three phases of evaluation and that evaluation will be repeated each term that course is taught.

Challenges

The College of Graduate Studies at UWS offers primarily fully online programs and therefore was selected to pilot ECET. The following are examples of challenges identified during the pilot. We have also identified possible solutions to each challenge:

Initial Challenges

Possible Solutions

Some courses need to use assessments that involve observation of students performing skills in settings that involve interactions with clients or patients. Data capture in these situations is technologically challenging.

Using recorded videos of student-client interactions along with assignment rubrics to assist with accurate grading of clinical skills.

The first round of data collection revealed there were some learning outcomes that lacked assessments and some instances of mismatch between learning outcome level (Bloom’s Taxonomy) and the assessment strategy.

Faculty may choose to improve these areas as part of their action plans in the ECET reports.

Volume of data and reporting required to track every course every term – and finding efficient technology to support the process.

The project leads have been using Excel spreadsheets for the ECET reports. Basecamp, a web-based project management software application is used to track due dates and assign steps in the process. UWS is evaluating more efficient tracking and reporting options going forward.

Lessons Learned

This initiative has been very faculty-centered from the beginning, and that’s a major reason why it is proving to be a success! Faculty are in the best position to initiate course changes in order to improve student achievement of learning outcomes.

Start with the “low-hanging fruit.” Certain courses were more readily adapted to the new system. Starting with them allowed us to learn how to run and improve this process.

Get started, even if everything isn’t perfect. Learning outcomes and assessments don’t have to be perfectly written or aligned in order for similar initiatives to succeed. This process is intended to allow for growth and improvement. As we have affirmed along the way, “Perfect is the enemy of good.”

While this project is still in its beginning stages, we have had some important wins such as engaging and getting buy-in from all UWS’s graduate program directors and developing a good system to keep the project on track. We look forward to reaping the rewards of systematically reviewing student CLO data and seeing stronger student achievement of learning outcomes.

Bernadette Howlett
Affiliate Faculty
Idaho State University
(worked for UWS until recently as Provost and VPAA)

Denise Dallmann
Dean, Center for Teaching & Learning
University of Western States

Dana Sims-Barbarick
Dean, College of Graduate Studies
University of Western States

Susan Donoff
Director of Institutional Appraisal & Accreditation
University of Western States

WCET began following the issue of data protection and privacy (DPP) in earnest over the past year by providing resources and monthly tips on our Data Protection and Privacy Issue Page. We recognize that this growing and complex issue is something that should be understood by non-technical staff, faculty, and students, as well as IT staff. Data Protection is not just an IT issue! Everyone has a data protection role, from digital citizen to cyber superhero (cape not included). It is important to remember that data protection and network security are the responsibility of all members of the institution or organization community.

Higher education has many assets to protect including personal data of students and staff, research and institution information, as well as maintenance of network-dependent infrastructure. The Department of Education (Department) recently warned universities that they must improve their identity management to protect students receiving financial aid from compromising their personal information during phishing attacks. While protecting the students is critical, we must also protect faculty and staff, as well, as shown by the recent Department of Justice indictment.

Tools That Don’t Say “BOO!”

While the Department has put together multiple tools to help improve compliance from a data-protection perspective, members need to realize compliance is the least of the institution’s worries. The Department has agreed to audit the language to review IHE GLBA (Gramm-Leach-Bliley Act)-compliance starting in 2019, per the FY2018 submittal to the U.S. Government Accountability Office(GAO.) To date, while the Department may have suspended individual or organizational access to the U.S. Federal Student Aid (FSA) systems; the Department has not taken any punitive actions nor eliminated Title IV participation in response to a data breach or security compromise, yet.

Compliance should be considered a bare minimum, but how well would a compliant approach protect you? Unfortunately, when reading the GLBA statutes, the needed level of specificity is almost entirely lacking from the legislation. Further, what danger lurks within your walls? General Brigadier Gregory Touhill, appointed by President Obama to be the first Federal Chief Information Security Officer of the United States, recently stated that 95% of issues arise from the unspeakable acts of negligent leaders or staff. From a data-protection reality, a GLBA audit may be too flimsy to provide true direction for improvement if the threat is the one facing you in the mirror. It is also frightening to picture fighting off bad guys (or scary monsters) with a wet noodle. Luckily, there is at least one Department recommended way to achieve stronger data protection.

Don’t Be Scared of These Data Protection Standards

In Dear Colleague Letter 16-12, the Department suggested a higher data-protection standard that includes clear controls for non-federal systems: 800-171. The National Institute of Standards and Technology (NIST) publication, 800-171, is a smaller list of technical controls that are appropriate to protect unclassified information, rather than the terrifying list included in NIST publication, 800-53. Even better, NST recently published a guide to assess the requirements to protect data to the 800-171 standard – 800-171a. This guide includes supplemental templates for a system security plan and a plan of actions and milestones, to assist you and your team in jumpstarting the heart of your data protection documentation, in case your existing library is ghastly. The 800-171a can be used to self-assess, or to inform a 3rd-party assessment, perhaps for submittal to the Department or an auditor.

Missing from this approach; however, are the external dependency aspects required by GLBA that may be included in future audit language; for example, how are you managing your data protection at 3rd-party servicer or contractor-supplied sites? How are you inspecting or examining those controls? How often to you check? Additionally, 800-171 and 800-171a both take a very system-level approach, whereas the GLBA requirements focus on consumer data-protection. Please be warned that you could perhaps focus too much on the oyster shell and not enough on the data pearl within. Fear not, as 800-171a can be customized by a savvy cyberteam, or by your out-sourced team, if your cyberteam is still forming.

Privacy Laws – Ideas for Treats, Not Tricks

With a plethora of new privacy laws potentially in the queue to follow up the California Consumer Privacy Act and GDPR, the postsecondary community needs to solidify three primary areas (which will likely take time, so don’t wait until the last minute):

Employee awareness/training – During very recent engagements with the postsecondary community, it is evident that staff are still the biggest area of risk for potential privacy incidents. Employees should be aware of the laws to ensure that data being transferred on student and staff records are being done in a secure manner.

Vendor & 3rd Party Clauses – The second greatest risk to your organization is that of your third parties and how they handle your data. From IT and HR infrastructure functions, to software vendors, to researchers utilizing your data, it is imperative that you have strong data protection, data breach, and potentially financial penalties (that you can pass onto the vendor, since many of these new laws an impose fines on your organization) for failure to adequately protect your data.

Transparency – Most of the new laws have a focus on transparent use of personal information. This likely means your privacy notices are in desperate need of updating. Unfortunately, this will require a bit of effort, as your institution will need to inventory all of your various uses of data, including your administrative, research, and alumni association use. Your organization will need to clearly articulate:

who has access to data,

data use purposes,

the avenue for students and staff to “opt-in” to sharing of data outside of those uses that are strictly required to provide services to individuals.

National Privacy Landscape

On the national privacy landscape, congress just recently held a hearing as they are considering national legislation to address consumer privacy. Privacy experts leading the charge with GDPR and the California Consumer Privacy Act as well as privacy advocates from the Center for Democracy and Privacy and the Georgetown Law Center on Privacy & Technology essentially agreed that the current U.S. laws need an emphasis on transparency and consumer protections. This comes at the heels of some of the largest custodians of U.S. consumer’s data (Google, Amazon, Apple and others) advocating the need for a national consumer privacy law to get ahead of divergent state-based laws on consumer privacy.

Don’t Be Afraid!

We do not want institutions and organizations to be afraid. Our goal is to share the need for the development of best practices for data management and to safeguard your institution or organization from exposure to a data breach. Understanding that EVERYONE at an institution or organization must take personal ownership is key to a strong data protection plan! The resources shared here will provide initial talking points for you to use for discussion.

Look for WCET to share more information in the form of webcasts and resources on the WCET Data Protection and Privacy Issue page.

]]>https://wcetfrontiers.org/2018/10/31/data-protection-privacy-unmasked/feed/0hacking-3112539_1920linsraedownsa pumpkin iwth a face carved into it and a candle inside illuminating the facea jack 'o lanternCheryl DowdTiina Rodrigue headshotbrheadshot.jpgCC LogoThe Role of Procurement in Digital Accessibilityhttps://wcetfrontiers.org/2018/10/23/procurement-in-digital-accessibility/
https://wcetfrontiers.org/2018/10/23/procurement-in-digital-accessibility/#commentsTue, 23 Oct 2018 12:00:07 +0000http://wcetfrontiers.org/?p=10514WCET and the Online Learning Consortium (OLC), in conjunction with the National Center on Disability and Access to Education (NCDAE is a partner with WebAIM), jointly offer this blog post on a topic of national interest to education communities. This post is part of the on-going collaboration on accessibility issues between WCET and OLC.

Join us for our upcoming Halloween webcast: Web Accessibility: Trick or Treat, where our panel of “been there, done that” experts will share their tricks, tips, and strategies for making accessibility a treat, and a little less scary.

Enjoy the read and enjoy your day,

Lindsey Downs, WCET

Many of us have heard of the Law of Holes; “If you find yourself in a hole, stop digging”. The deeper the hole, the harder it is to get out.

For institutions working to create a culture of digital equity or legal protection, institutional accessibility can start as a hole from which you must climb out. One of the many shovels that work to deepen the accessibility hole is the procurement of goods or services that are not themselves accessible. However, accessible procurement can offer a ladder, helping you get out of that hole more quickly.

In today’s blog post, I outline five actionable steps that should help you stop digging deeper, and help you get out of an accessibility hole, in part, through accessible procurements.

Step 1: Understanding the Criticality of Accessible Procurements

Every institution “procures” goods and services for their digital environments. Examples include the licensing of an institutional LMS or financial system, contracting with outside developers to create an online registration system or web templates for departments to use, the decision to use Google Docs in an academic program, or even the selection of open educational resources or digital journals by faculty in coursework. Whether this is done by central administration, by purchasing staff, or by individual faculty, the institution is responsible for the ultimate accessibility of that which is procured and used.

This responsibility hearkens back to the requirements put in place by the Americans with Disabilities Act in 1990. Institutions were responsible for physical access of the built environment (e.g., ramps, elevators, and disability bathroom stalls to name but a few). This responsibility resulted because the institutions themselves were in charge of the bid requirements, and in selecting architects and contractors. As such they were viewed as having control over the finished product, or at least being able to fix the finished product. Moreover, renting or leasing spaces from others did not remove the obligation to provide access to the built environment; the “it’s not ours so we should not have to fix it” defense was ineffective in the courts.

As we fast-forward into the digital world, many of the same arguments apply. While we know that an institution can choose to procure things that are not accessible, they are on the hook to make them accessible if students, faculty, staff, or community members with disabilities need access. This need occurs with stunning frequency and is often the genesis of complaints and litigation. One smart move by an institution is to shift the responsibility of making these systems accessible back to those who developed them rather than accept that responsibility, cost, and liability. This is an important mindset shift: To procure items that are accessible from the beginning, so that YOUR resources are not tapped as you work toward accessibility conformance.

This procurement logic has common footing with security issues in higher education. More institutions now include security features as a precursor to procurement of many technology systems. Accessibility requirements during a procurement process would function in the same fashion.

Procurement is often confused with purchasing. Yet it is much broader than a purchase. In fact, while many campuses have procedures in place for purchasing, often there is a dollar threshold (e.g., $5,000) that will spring into effect the use of institutional purchasing policies. While this will catch larger purchases, some items that can have broad impact may go undetected or unexamined because they are either free or do not meet the dollar threshold that puts them through official purchasing processes. Think of the impact of freely available products on campus (e.g., WordPress, Google Calendar, Google Docs, or YouTube) when used by an institution.

So, procurement is simply the act of obtaining something (i.e., purchase, license, acquire, rent, select, borrow, gather, curate, develop, or contract). Remembering this will help you recognize where you may be vulnerable, and where you may need to act. This reflection is an important first step.

Step 2: Include accessibility in procurement

Many institutions currently have, or are creating, an institutional policy to cover the accessibility of electronic and information technologies (E&IT). Yet many did not include procurement specifically in that policy. Doing so can have positive effects. For example, in 1998, Congress amended the Rehabilitation Act to include a requirement that the Federal Government would make all their own E&IT accessible to citizens with disabilities.

One brilliant aspect of this law is that it was tied to Federal procurement policies. Section 508­ is that aspect of the law which requires Federal Agencies to develop, procure, maintain, and use accessible E&IT. The law never said that vendors or makers of E&IT needed to make their products accessible. On the contrary, it only required that Federal Agencies restrict their procurements to those things that meet their accessibility criteria, with provisions for procurements of the “most accessible” when no such product line fully conforms to the standard. The purchasing power of the federal government created market-driven changes which are still in effect today.

This is a model that many in higher education have decided to embrace and emulate. While establishing institutional policy on accessibility is important, assuring that this policy flows to procurement is smart. What a policy can do is set the occasion for institutional expectations, for budgets, and for processes that will reinforce the end goal of accessibility.

Examples of institutional standards or policy that include accessible procurement:

Step 3: Place accessibility into every RFP/RFA, and contract for E&IT

When an institution has a policy, they develop procedures to support that policy. For accessible procurements to take place, you would likewise want procedures to follow.

For those procurements that result in a purchase, an internal or external work for hire, or a license, an institution will often begin by creating a Request for Proposal (RFP), or Request for Application (RFA). As these go out, they set the expectations for each vendor or contractor who will respond. Because of this, it is critical that accessibility becomes a required feature of the procurement. Here are four things that you may want to include as part of this announcement phase:

Request that the vendor provide you with information on the conformance of their product to this standard; or in the case of a contractor, guarantees that performance will include conformance. While vendor information can take several forms, many institutions have elected to use the very same Voluntary Product Accessibility Template (VPAT currently v 2.2) as is used in Federal procurements. This is simply because many vendors have them already and understand this process. It is critical to understand that VPAT’s are most often created BY the vendors themselves. Know that they are incentivized to communicate to you that everything is fine with accessibility. With that said, a thorough and accurate VPAT can be very informative. Maybe more importantly, it provides an accessibility claim that should be referenced in the contract. Here is an example of a VPAT for the LMS, Canvas.

State if you intend to evaluate the materials they submit. Few purchasing offices are staffed with individuals that have the technical knowledge to review VPATs or other documentation according to the technical standards. Also, occasionally VPATs are filled out in ways that are too vague to provide a clear picture of conformance (although this should be a red flag when evaluating vendors). As such, you would need processes in place to engage in your own due diligence, and spot check what they provide to you. An accessible procurement team can be identified by the institution to help evaluate what was submitted; often they come from the institutional accessibility team.Be mindful of what the vendor represents to you, and make sure you spot check their entire product. For example, it does you no good if an LMS vendor talks about the accessibility of the student interface but does not mention the inaccessibility of the instructor interface. Or that their core product is accessible, but they fail to mention that none of the extensions you plan to purchase from them and use with their core product are accessible. If you do not like a VPAT process that feels like the fox guarding the hen house, feel free to require an independent third-party evaluation in your announcement.

This is more common that you might think. For example, the California State University (CSU) System requires that vendors of larger procurements must offer an independent third-party evaluation report. This is in line with their belief that the institution should not have to bear the cost of evaluating vendor products; which is what happens when an internal team performs an evaluation; it becomes an institutional cost through time and effort of personnel. The CSU also includes a requirement that finalists demonstrate their product and include accessibility in that demonstration (e.g. a CSU staff or student with a disability might use their assistive technology to run the program during part of the demonstration). The demonstration is requested as a way to validate the claims of the vendor and engage in due diligence prior to procurement. No matter your process for evaluation, it should be fully detailed in the RFP/RFA so you are attracting those serious about accessibility. An example of this can be found at the CSU Vendor Accessibility Requirements.

Announce that the vendor’s accessibility claims will be presented in the contract as an express warranty for the current product as well as any updates. This gives you room to require that accessibility deficits that are found later are changed immediately. Moreover, it will set forth the expectation that future updates include conformance to existing accessibility standards. A common topic of accessibility conversation on campuses across the nation is how a recent update broke accessibility features, or how a new feature development did not include it whatsoever.While having an accessibility warranty in your contract could also set forth a breach of contract by the vendor, nobody really wants it to get to that stage. Yet, pulling back your costs could offset a negative fiscal impact amid a legal complaint or if the vendor refuses to allow changes. You may also want to notify the vendor that you will require them to provide you with an accessibility development roadmap to be added to the contract for any feature where accessibility is not in current conformance (e.g., where items are not “supported” on the VPAT if you use such a thing). This could then bind them contractually to stick with the roadmap and timelines, depending on other contractual items. Having this in your contract language may also demonstrate institutional good faith should a complaint arise. But remember that having a promise of accessibility is not the same as having a product that is accessible. Until you reach that time, your institution will have to bear the cost of accommodations, along with a few sleepless nights as you worry about broader legal liability.

Here are examples of language, or information given to vendors for accessible procurements:

Step 4: Create systems to support accessible procurements from faculty and staff

What if a free or low-dollar procurement is made by faculty or staff? No matter who initiated the procurement, the enterprise is responsible for accessibility if an employee or patron with a disability requires it. Some campuses now have processes in place where faculty and staff engage in sharing information that will help the institution determine risk and ultimate cost. One example of this can be found at the University of California at Irvine (scroll down to the checklist form). They ask faculty and staff to fill out a checklist so that accessibility and security concerns can be reviewed centrally. Depending on the result, a technical review by central staff may be required.

You will not catch everything, but having a system in place certainly helps. While some accommodations will occur, keep your eye on preventing this need. Courts have ruled that institutions have an affirmative obligation to work in advance of the need for auxiliary aids and services; in other words, you should have known someone with a disability would need to access this at some point and you should have something that works for them. Having policies and procedures in place such as these shows a good faith effort on the part of the institution.

I want to provide you with one more set of resources before I end. There is much discussion in the higher education accessibility community about how each procurement office is duplicating the efforts of others as each evaluates products on their own; to a certain extent we may all be reinventing the wheel. Here are some groups that are trying to share their information with others:

Be aware, however, that in many instances what you will find is limited information. For example, the versions of products may be unknown. You may not know much at all about what was evaluated (scope), how it was evaluated (methods), or the skills of the person who did the evaluation (expertise). Moreover, we don’t have any data on test-retest or inter-rater reliability of these evaluators or evaluations. So, are repositories like this helpful? You would not want pin all your institutional risk on these summaries, but the content of these repositories are wonderful places to start collecting information you can use in a broader process to verify products on your own. Perhaps instead of reinventing the wheel, you only duplicate the effort of two spokes?

One very promising framework for sharing information comes from the Department of Homeland Security. It is called Trusted Tester. It is a free course (available to anyone), that culminates in a performance-based certification exam. It was recently updated to reflect the refreshed Section 508 standards. If the learner passes the performance-based course exam, it verifies that they have the demonstrated skill to perform a systematic accessibility evaluation.

When evaluation results are based on a common methodology by persons with common confirmed expertise, the results can be “trusted”. Many groups have looked at the unique needs of the higher education community and wondered if Trusted Tester collaboratives might be part of a solution (e.g., the collaboratives could share information obtained from a common metric by certified individuals, thus reducing individual evaluations of all products). As this idea works its way through decision-making bodies, knowing that some are sharing the little information they have can still be useful.

Stop Digging. Create an Accessibility Procurement Process

Creating and using a procurement process that includes a focus on accessibility will help your institution stop digging a deeper accessibility hole. Over time, with training, and updates to your digital infrastructure, you will be above ground.

I look forward to discussions on this blog post below. If you would like to discuss issues of accessibility with me directly, don’t hesitate to contact me Cyndi.Rowland@usu.edu.

Cyndi Rowland
Executive Director, WebAIM, and
Technology Director
National Center on Disability and Access to Education
All housed at Utah State University

]]>https://wcetfrontiers.org/2018/10/23/procurement-in-digital-accessibility/feed/1linsraedownsquote: Procurement is more than purchasing, it is the act of obtaining something whether by purchase, license, acquisition, rental, selection, borrowing, gathering, curating, developing, or contract.quote box: No matter who procures digital applications, content, or supports, the institution is ultimately responsible to make it accessible to employees and patrons with disabilities.quote box: Procure items that are accessible from the beginning, so that YOUR resources are not tapped to make them accessible.quote box: The law does not require that vendors create accessible products and services, but it does require that you have them available to use when needed. It is up to you. Procure that which is accessible, or spend precious resources making it so.quote box: Four things to go into every RFP/RFA and contract 1. State your technical accessibility standard 2. Request the vendor gives you documentation of their conformance 3. State if you will evaluate their product or service 4. Communicate that these claims will appear in the contract as an express warrantyYou will not catch everything, but having a system in place certainly helps.A shovel resting on some dirt in a wheel barrelHeadshot of author Cyndi RowlandCC LogoAll About Portland: Get Ready for #WCET18https://wcetfrontiers.org/2018/10/21/all-about-portland-get-ready-for-wcet18/
https://wcetfrontiers.org/2018/10/21/all-about-portland-get-ready-for-wcet18/#respondSun, 21 Oct 2018 12:00:59 +0000http://wcetfrontiers.org/?p=10504To gear up for the WCET Annual Meeting this week we welcome Jim Friscia, Portland native, to give us a grand, virtual tour of the City of Roses! While we definitely hope you’ll stay with us during the Annual Meeting convening times… this post will give you lots of great food and fun options for evenings (or for the extra days you may have planned into your trip!). Thank you Jim for providing the great ideas for visiting beautiful Portland.

Enjoy the read and enjoy the city! I’m looking forward to seeing those of you who can attend next week. Join us on Twitter using #WCET18 to follow us throughout the conference, I’ll be live tweeting the events!

– Lindsey Downs, WCET

Greetings from semi-sunny Portland! Yes, it’s the middle of October and the sun is still shining. Will it last through #WCET18 this week? We’ll see. But rain or shine, there’s plenty to do in Portland (a.k.a the City of Roses, Bridgetown, Beervana, P-Town, Rip City, Stumptown, and PDX).

Before the 26th WCET conference held here in 2014, Loraine Schmitt of Portland Community College and I each wrote posts (Loraine’s / Jim’s) about things to do in the city. I’ve combined and revised them a bit for this year’s conference. Any resemblance to the previous posts is absolutely intentional.

Has much changed in Portland since 2014? Hmmm … other than thousands of more folks moving here, unending construction (especially on the bourgeoning east side), more traffic, a new MAX light rail line and stunning bridge (Tilikum Crossing) over the Willamette, more award-winning chefs, restaurants and food carts, and the Portland Timbers winning the MLS Cup in 2015 and the Portland Thorns winning the NWSL championship in 2017 … not much.

If you’re a morning (or anytime) walker or runner, from the Marriott just cross the street and head north along Waterfront Park to the Steel Bridge. Cross the bridge and head south along the river’s Eastbank Esplanade, crossing back to downtown on the Hawthorne Bridge. You can also continue south on the Esplanade to the Tilikum Crossing and then back through the South Waterfront. Here’s a link to more fabulous walks around the city. You can find some of the best walking maps for touring the city at portlandmap.com. And, of course, we are a city of bridges that are fascinating to explore.

Portland is rich with coffee, tea, wine and locally distilled spirits. But, if you’re interested in experiencing Beervana, you can check out this map at PortlandBrewPubs’s web site of brewpubs in the city. Select a neighborhood, check out the choices, and either walk or ride the MAX, Streetcar, bus or take Uber or Lyft. You cannot go wrong if you want to make it easy on yourself and head over to the Rogue Pearl Public House and the Deschutes Brewery.

Shop and Browse

Did you know Oregon does not have sales tax? Yes, you can shop tax free in Portland! Choose from NW 23rd Ave, the Pearl District, Downtown, NE Alberta Street, SE Hawthorne Boulevard, or on the weekend visit Saturday Market (rain or shine, and on Sunday, too) to check out up to 250 artisans sharing their work. Stop in and listen to some music while you enjoy a tasty meal from one of the food vendors. Of course, right across the street from the hotel is the Riverplace Marina. Stop in for ice cream, sushi, drinks, or browse the shops just steps from the hotel.

Photo taken inside Powell’s Books

You must have heard about Powell’s City of Books. The downtown store on E. Burnside takes up an entire city block and you need a map to help you find your way around the store’s rooms and stacks. One of the best places to spend a rainy day (or any day) in Portland!

Relax and Explore

Without leaving the city, you can take a little break and visit the beautiful Lan Su Chinese Garden created by artists in our sister city, Suzhou. It’s not just a garden, but its work of art, complete with a teahouse.

Just to the west of downtown is Washington Park, where you can find the Oregon Zoo, the International Rose Test Garden, and the Portland Japanese Garden, one of the most authentic outside of Japan. The fall colors are absolutely stunning.

Photos taken at the Japanese gardens in Portland, OR

Are you a hiker? There are over 70 miles of trails in Portland’s Forest Park. This is a jewel of a wild urban park in Northwest Portland that you can easily get to via public transportation.

If you come early or stay late, you may want to take advantage of our rich climate and head out of town. Take a drive out on the Historic Columbia River Highway. Stop in to see Multnomah Falls, drive on to Hood River, or go all the way to Mt. Hood. If you want to head west, check out Cannon Beach, Lincoln City, or Pacific City on the Oregon Coast and stop in for some wine tasting on the way at one of the Willamette Valley Wineries.

Also, if you enjoy live music, Portland has a wealth of options from local neighborhood clubs to large venues. If you want to know what’s going on, check the Willamette Week event calendar, or check out my occasional blog of live music recommendations, Jim’s Music Notes.

As you’re networking and exploring new ideas and innovations at the 30th Annual Meeting, be sure to find a little time to get out and experience Portland, too!

Jim Friscia
eLearning Consultant
Portland, OR

]]>https://wcetfrontiers.org/2018/10/21/all-about-portland-get-ready-for-wcet18/feed/0portland-841428_1920linsraedownsPhoto of a wall with the words "smellboud adj: held as if under a spell by the scent of books"Photos taken at the Japanese gardens in Portland, OR - one of a tree surrounded by green moss and foliage, second of a dragon statueauthor headshot jim fCC LogoTransforming Our Model for Student Success: The WRAP Initiativehttps://wcetfrontiers.org/2018/10/19/the-wrap-initiative/
https://wcetfrontiers.org/2018/10/19/the-wrap-initiative/#respondFri, 19 Oct 2018 12:00:02 +0000http://wcetfrontiers.org/?p=10491Welcome to the final blog post in our WCET Outstanding Work (WOW) Award blog post series! Today we are joined by Jason M. Ruckert from Embry-Riddle Aeronautical University – Worldwide, to discuss their 2018 WOW Award winning initiative: Worldwide Retention, Affinity, and Persistence or WRAP.

The WRAP initiative encompasses immersive solutions which include the incorporation of virtual labs into courses through a centralized virtual hub, the creation of individual academic advisor webpages, a new student orientation, a virtual student readiness and resource course, personalized degree maps, virtual new student on-boarding, virtual career services, and a virtual community.

Our Challenge

The explosive growth in distance education is changing the global higher education landscape. Within the United States alone in 2016, over 6,000,000 students took at least one online course. One out of four college students take at least one class online and these numbers are growing year to year (Seaman, Allen, & Seaman, 2018). This growth is well documented, and many institutions are changing their educational models to ensure distance education is at the forefront. At Embry-Riddle Aeronautical University-Worldwide Campus, we’ve seen a very similar transformation; our virtual enrollment went from 9% in 2004 to 91% in 2018.

This posed an enormous challenge for us: how do we evolve our infrastructure from 140 campuses delivering face-to-face coursework to a primarily virtual campus that guarantees our students every single opportunity they would have taking courses at a traditional campus?

Transforming our model

Embry-Riddle provides instruction through a learning system that leverages online and face-to-face delivery methods and a network of approximately 140 educational facilities designed to support student advancement in the U.S. and abroad. However, in 2004 we noticed a dramatic shift in our students’ preferences for online coursework. Our annual growth rate is certainly at the higher end of industry trends, where distance education grew by 5.6% from the 2015 to 2016 academic years across higher education (Seaman et al., 2018). Embry-Riddle’s transformation is unique. We had already been successful in distance education for decades, but our student demand of online education was accelerating at such a rate that we had to revamp our entire infrastructure to ensure student success. This brought up several questions:

If we didn’t have that face-to-face relationship with them, would our students fail to persist?

Would we have less students that would take courses each year?

Would they lack affinity to the University?

I would be confident in saying that none of us at the institution would have envisioned a complete 180-degree change in our enrollment to online education this quickly. Distance learning creates unique challenges to engage our learners, make them feel a sense of affinity with the university, and immerse them in course topics due to the lack of real-time interactions and geographic dispersion (Kruger-Ross & Waters, 2013). Distance learning students desire and expect to have the same real-time interactions with their instructor, staff, and learning objects they would experience if attending a traditional campus or taking face-to-face courses. A lack of real-time interaction with faculty, course content, and staff can lead to students feeling a sense of isolation, leading to higher attrition rates (Collins, Weber, & Zambrano, 2014). We knew a new strategy with significant funding and infrastructure would be a necessity to ensure students had an unparalleled experience.

The Solution

Our goal was to ensure students had every single opportunity they would experience on our residential campuses but offered in a virtual format. Embry-Riddle Aeronautical University Worldwide viewed the solution to creating an immersive experience and a sense of belonging to be holistic in nature. No single technology initiative could occur in isolation and meet the multiple needs and desires of our students. Our students want a “college-feel,” and now they want it from the comfort of their own home.

So, our goal is to increase affinity towards the institution. We want students to leave with an exceptional education and to feel like they just had the greatest experience. Therefore, we have implemented several technology-based solutions and enhanced support structures to address the multiple needs of our students through our Worldwide Retention, Affinity, and Persistence (WRAP) initiative which began in 2014. These immersive components include:

The Impact of WRAP

Advisor-specific webpages have become some of the highest return visit hits on our campus webpage.

New student matriculation rates have increased over 10% since the inception of this initiative, while applications and admits have remained constant.

Persistence rates have increased 17% since the inception and overall individual course registrations have increased 24%.

We have also experienced a 27% increase in overall student enrollments during this initiative.

Since implementing the new student orientation, completion rates have increased from 55% to 100%, since it is now available fully online and is required before matriculation.

An abundance of positive qualitative feedback has also been collected from students on their experiences using the virtual labs, virtual on-boarding, and degree maps available to them.

Before commencing our virtual community, we surveyed students and 72% of indicated they would be actively involved in the virtual community, once fully implemented.

Virtual Student Readiness Session

It’s truly rewarding to watch our campus do a complete 180-degree turn, 9% virtual in 2004 and now is 9% face-to-face in 2018. To accomplish this and have increases in matriculations, persistence, and graduations as well as keeping a population of over 24,000 students active by completely overhauling our model is incredible.

Student Feedback

Students are excited about the WRAP initiative. Here are a few comments from them about the various aspects of WRAP:

Thank you for the revised degree map! That actually made me feel a lot better about my progress in this degree. It’s been hard lately to picture another year of school, but this definitely puts it in perspective— getting closer!

Being hesitant about learning online, it was my advisor’s webpage with her video welcoming me to the University and telling me how she was going to get me through this process which alleviated my fears.

The ERAU Virtual Hub is one of the top teaching applications because it allows students to interact in the actual environment. Many times it is better to do an assignment with hands on experience, and this does exactly that by bringing students up close and personal with real engineering concepts.

I consider myself a gamer and this aircraft investigation lab adds the fun back into education while still providing the me the education I need to be successful.

Why can’t education be fun like this? Well, I guess it can, please add more of these virtual labs asap!

Having someone assist me with resume writing and applying from jobs from the comfort of my home was something I was not expecting from a University.

Virtual Labs

Future Plans

At Embry-Riddle we have this incredible history with distance education so there is an ongoing commitment to expand the WRAP initiative. We want to continue evolving for our students and will continue to investigate technology-based learning solutions that will propel our students into the future. We believe we are only at the cusp of what is possible in online education.

A Virtual Lab

A Sincere Thank You

Embry-Riddle Aeronautical University is truly grateful to WCET for presenting us with this WCET Outstanding Work (WOW) Award. We are humbled and honored to receive such a prestigious award and contribute to the advancement of technology-enhanced learning solutions. We will continue developing new innovative products for our students and industry.

]]>https://wcetfrontiers.org/2018/10/19/the-wrap-initiative/feed/0quotelinsraedowns2018 WOW award logo. The WCET logo inside of a black box. Below the wcet logo, text reads "WOW award 2018." Underneath the black box reads "WCET Oustanding Work Award"Screen shot of advsior page. Shows photos of and information on student advisors.A screen shot of a virtual student "launchpad," showing a video conference with an advisor and a chat with other students.Screen shot of a virtual labScreen shot of a virtual lab with an interactive investigation of a plane crash. A character stands in front of a crashed plane.Author headshot Jason R.CC LogoUNLV Pays a Cost for Not Notifying Students about Charges for Proctoring Serviceshttps://wcetfrontiers.org/2018/10/17/unlv-pays-a-cost-for-not-notifying-students/
https://wcetfrontiers.org/2018/10/17/unlv-pays-a-cost-for-not-notifying-students/#respondWed, 17 Oct 2018 12:00:43 +0000http://wcetfrontiers.org/?p=10480Cheryl Dowd, Director of the State Authorization Network, and I have been presenting this summer about the status of the federal state authorization regulation. In those presentations we remind people about other federal regulations that remain in place.

The one that has most surprised those in our audiences is the requirement that students be notified at registration if there are any extra fees in course, such as for proctoring. Many of those in the audience said that they notify students about these costs in the syllabus for each course, which is long after the student registers.

Here is the wording from federal regulations, Chapter 34, §602.17(g)(2) regarding institutions of higher education assuring that they know the identity of students in distance education courses:

“Makes clear in writing that institutions must use processes that protect student privacy and notify students of any projected additional student charges associated with the verification of student identity at the time of registration or enrollment.”

Today’s guest blogger is Leeann Fields from the University of Nevada, Las Vegas. She tells us a story about the consequences for one course in not providing the proper notification for extra costs for proctoring services. Thank you, Leeann!

– Russ Poulin, Director, Policy & Analysis, WCET

Our institution recently faced a situation regarding students not being notified of additional fees in a course during the registration process. The situation occurred over proctored exams. Our arrangement for proctoring has students pay a fee to the proctoring service provider for each proctored exam in a course. Students in this course were not made aware of this requirement before they decided to register.

It Was Our Error in Not Notifying Students of Proctoring Charges

UNLV offered an online course in the Spring of 2018 that included four proctored exams. The first three proctored exams at one hour were $15/exam; the final exam was two hours at $19.75, for a total additional fee per student of $64.75, which each student would additionally pay during the course.

Typically, if there are extra charges, the following notification is listed in the registration system for students to see prior to enrolling in the course: “This course has Proctored Exam(s). Additional verification of identity & additional charges required.” A URL is also given to students for students to learn more in FAQs.

For this particular course, this notification was not provided.

A Student Objected and Did Some Research

One student in the course, upon reading the syllabus, was angry about not knowing about these additional fees ahead of time. The student researched the matter and discovered that he should have been told about this at the time of registration.

The student went to both the instructor and the department chair who told him proctored exams were a requirement of the course, and he had to abide by that for the integrity of the course. An offer was extended to the student to come to campus and be proctored on location at no charge. The student objected to this as he declared it was a fully online course, and as such, the institution could not require him to come to campus.

When the Institution Did Not Help, an Appeal to the System’s Board Was Made

The student, after feeling he was making no headway within his department, appeared at the system’s Board of Regents meeting and made the issue known there. He arrived armed with citations of the regulations covering the need for such a notification. The student further went on record stating he was not only making the complaint on behalf of himself in the course, but he was “carrying the torch,” if you will, for all the students in the course.

The Regents were quick to realize the student’s complaint had not yet been addressed by the Dean of the College or any level above that rank. With that in mind, the Regents referred the issue back to UNLV, allowing our institution another opportunity to try and resolve this issue to the student’s satisfaction. This would be similar to a SARA complaint first being sent to a state portal entity with the institution never having had an opportunity to resolve the matter.

The Regents left the door open for the student to reappear if an adequate resolution could not be reached. When the Dean was notified of the complaint made at the Board meeting, the Dean turned to our Educational Compliance staff for guidance on a resolution.

The Dean was assured that the student was correct about not having proper notification. However, removing proctored exams from the course was not an option. The instructor and department held fast to the notion that all exams in the course had to be proctored for academic integrity. Also of note, by this time, the students in the course had already paid for and taken two proctored exams. Educational Compliance personnel at UNLV were instrumental in proposing and implementing the solution that UNLV should cover the cost of the proctoring this one time for all students in this course, which addressed the concerns of the student, the instructor, and the department.

Finding in the Students’ Favor; The Institution Had to Pay

The total cost for proctoring in this course was just over $7,000.00 (~110 students x $64.75). The Office of Academic Affairs agreed to pay half the cost and the particular College which offered the course agreed to pay the other half.

The University had to financially figure out how to transfer $30.00 back to each student in the course to reimburse them the $30.00 they had already paid. For the final two exams, the proctoring service changed the billing arrangement for this course only from “student pay” to “institutional pay.” At the end of the course, the proctoring service sent a bill to the institution for the remaining costs associated with exam #3 and the final exam.

About Our Student in the Story

The student shared that both his upbringing and educational experiences in life were heavily underscored with people who taught him about having a duty to serve and that of fighting to protect one’s rights and freedoms in particular fighting for those who are less fortunate. Those influences may help you to understand why, in the student’s own words, he “saw a need to question the policy” and take up the cause for the “students who did not have the time to read through policy.”

Lessons Learned

Certainly, a take-away message here is that it is important to recognize the myriad combinations of education and experiences our students bring to the table. They are, after all, in higher education because they seek to know and/or seek to create new knowledge. With regard to your students at your institution, never take for granted that an issue is not worth someone’s time.

The fortunate part that came about from this costly lesson is that it did show UNLV leadership the value of having a SARA role, such as mine, within our institution to turn to for guidance. It was proof positive that this role is necessary and valuable. Had UNLV not had the internal expertise to guide the Dean on a fair solution, our institution could have landed back in front of the Regents. Instead, we avoided having to have the Regents intervene, making this an even more public and embarrassing situation, and UNLV demonstrated our commitment to both compliance and resolving matters in a fair manner.

Finally, the moral of this story: Just in case anyone doubts it, there is a cost for not being compliant!

]]>https://wcetfrontiers.org/2018/10/17/unlv-pays-a-cost-for-not-notifying-students/feed/0moral of storylinsraedownsa man sits working independently at a computerText image says: The total cost for proctoring in this course was just over $7,000.00author headshotCC LogoThe Department of Education’s Plans for Overhauling Accrediting and Innovation Regulationshttps://wcetfrontiers.org/2018/10/15/the-department-of-educations-plans-for-overhauling-accrediting-and-innovation-regulations/
https://wcetfrontiers.org/2018/10/15/the-department-of-educations-plans-for-overhauling-accrediting-and-innovation-regulations/#commentsMon, 15 Oct 2018 17:02:33 +0000http://wcetfrontiers.org/?p=10471On Friday, October 13, the U.S. Department of Education published the unofficial version of its plan to establish an “Accreditation and Innovation” negotiated rule making committee. The final version should be published in the Federal Register today and includes the call for nominations to serve on the committee and three subcommittees.

You may recall that in July, the Department published a proposed plan and offered opportunity to comment by letter or in one of three public hearings. Russ Poulin joined with others from the 2014 committee in opining that there were too many issues for one round of rulemaking. The Department evaluated the comments and decided to make only minor changes:

“We believe the addition of a TEACH Grants subcommittee, scheduling additional days for the committee meetings, and the use of redlined regulatory text as the starting point of negotiations instead of issue papers will address concerns raised by commenters and ensure proper attention to each topic.”

What is the Structure of the Rulemaking Committees and Process?

There will be one negotiated rule making committee called the Accreditation and Innovation negotiated rulemaking committee.

The topic areas remain approximately the same from the July proposed plan.

There was a change in the number of topic-based subcommittees from two to three subcommittees.

Distance Learning and Educational Innovation Subcommittee,

Faith-Based Entities Subcommittee, and

TEACH Grants Subcommittee (the one that was added).

Subcommittees will make recommendations to the committee who will ultimately make determinations based on the subcommittee recommendations and committee discussions.

Subcommittees are not authorized to make decisions for the committee as only the committee has power to reach consensus on regulations.

The Department will seek consensus on issues divided into groups by the Department and the committee will have an opportunity to vote on each group.

Nominations for the committee and subcommittees are open until November 15, 2018 and should be submitted per the instructions shared in the announcement.

The Department plans to choose specific representation from certain organizations or groups as listed in the announcement.

The Department offered suggested representation for the subcommittees from certain organizations or groups noting that representation may include but are not limited to the list provided.

The schedule for the committee and subcommittees will include three and two day sessions (respectively) in each of the months of January, February, and March in Washington, D.C.

The Department seeks individuals from all sectors of institutions to ensure that there is sufficient representation and reflect diversity among participants impacted by these topic areas. You may wish to have a discussion at your institution or within your organization about nominations to determine appropriate representation with expertise to share your institution’s voice on a committee or subcommittee.

What are the Topics to Be Considered?

There is a large number of issues to be considered in this process. For those interested in technology-enhanced learning, here is a sampling of the issues that will be of most interest to you:

Accreditation. Both the requirements used by accreditors in overseeing institutions and the criteria used by the Secretary used to oversee accreditors will be reviewed.

On the latter they will emphasize “criteria that focus on educational quality and deemphasizing those that are anti-competitive.” This could result in major changes in the accreditor/institution relationship. It could also allow for new accrediting agencies or new ways for providers who are currently not accredited to gain pathways to federal aid. It is notable that there is not an accreditation subcommittee.

Barriers to Innovation. Addressing regulations that hamper innovation in educational programs is a repeating theme for this announcement. Included is consideration for “regulatory barriers in the Department’s institutional eligibility regulations and student assistance general provisions.” This could signal an interest in such changes as providing aid for new providers, opening aid for short-term programs, and other activities currently not eligible for federal grants or loans.

State Authorization. The Department attempted to delay the most recent regulation for this review. Their plan: “Simplification of State authorization requirements related to programs offered through distance education or correspondence courses, including disclosures about such programs to enrolled and prospective students and other State authorization issues (34 CFR 600.9 and 668.50).

Regular and Substantive Interaction.Frontiers has featured several posts on this issue. The Department will review how it is defined for both distance and correspondence education (34 CFR 600.2, 600.7, and 668.10). Presumably, this would apply to other modes of instruction, as well.

Competency-Based Education (CBE). The committee is to provide “consideration of regulations that are barriers to implementation of such programs.” This includes rules for direct assessment, term-based academic calendars, and satisfactory academic progress.

New Items that May Be Procedural or May Need to Be Watched. A couple new items regarding “programs that have not be funded in many years” or other “needed technical change” could be yawners or ways to make other changes not listed above.

A Few Other Issues to Be Considered. There are many items to be reviewed. A few others of note: definition of the “credit hour,” arrangements between an institution and another organization to provide part of a program, and program teach-out responsibilities. There will be subcommittees focused on rules for TEACH Grants and for Faith-Based Institutions.

Negotiated Rulemaking Timeline

Here is a timeline of important dates related to this issue:

Nov 15, 2018 – Nominations for negotiators deadline.

Jan-Mar 2019 – Committees meet.

Summer 2019 – Regulations released for comment.

By Oct 31, 2019 – Final regulations released.

July 1, 2020 – New regulations become effective.

Why Is It Important to You?

Quite simply, these discussions may result in the most sweeping set of changes witnessed in higher education in the United States since the middle of the last century. For WCET members and Frontiers readers, the issues highlighted for consideration are the very ones that will have a deep impact on our day-today operations.

That’s important!

WCET will work with other organizations to seek to nominate knowledgeable negotiators. We will also keep you informed along the way.

]]>https://wcetfrontiers.org/2018/10/15/the-department-of-educations-plans-for-overhauling-accrediting-and-innovation-regulations/feed/1blog1linsraedownsStreet sign with arrows pointing multiple directions. The arrow read "Compliance," "Rules," "Regulations," "Guidelines"timeline for netotiated rulemaking: Nov 15, 2018 – Nominations for negotiators deadline.Jan-Mar 2019 – Committees meet.Summer 2019 – Regulations released for comment.By Oct 31, 2019 – Final regulations released.July 1, 2020 – New regulations become effective.Cheryl DowdRuss PoulinCC LogoEdReady Montana: Scaling a Low-Cost College Readiness Initiative Statewidehttps://wcetfrontiers.org/2018/10/11/edready-montana/
https://wcetfrontiers.org/2018/10/11/edready-montana/#respondThu, 11 Oct 2018 12:01:36 +0000http://wcetfrontiers.org/?p=10455Today we continue our 2018 WCET Oustanding Work (WOW) Award blog post series! For this post, we’re joined by Ryan Schrenk and Robert Currie of the Montana Digital Academy (MTDA) with the University of Montana, who are here to tell us all about the EdReady Montana Program. EdReady Montana is an initiative to help students prepare for post-secondary education and/or future career goals.

Thank you Ryan and Robert for today’s post!

Join me in honoring these and our other WOW 2018 Award winners at our Annual Meeting in a few short weeks! Registration is open, but seats are going quickly!

Enjoy the read and enjoy your day,

Lindsey Downs, WCET

The EdReady Montana Program

The EdReady Montana program at the Montana Digital Academy (MTDA), housed at the University of Montana, has created a model to help address the problem of learning gaps for students in mathematics. These students hope to enter college and career pathways with the skills needed to succeed in their desired future goals. As one of five pilot states in 2013, the EdReady Montana program quickly showed that it made a difference for incoming freshmen at the University of Montana. The program then received generous funding for 3 years to roll out and field test the system. Followed by addition funding of 5 years, by the Dennis and Phyllis Washington Foundation, to build upon that success.

The program now serves over 500 individual educational organizations in Montana from upper elementary and middle school to high schools, colleges and universities as well as every adult basic education program in the state. The program evolved from one staff member presenting information about the program and setting schools up on the system to a comprehensive and replicable model of support and training for other states or large-scale implementations to follow.

In the early days of the program, this video was customized by EdReady Montana and used to outline the “educational problem” and also show users how the EdReady program worked to identify gaps and help students learn the material to master those concepts:

EdReady Regional Ambassadors

As intuitive as a technological program is, it does not run itself. Teachers are busy teaching, administrators are busy running schools. They need help learning how to best apply a program for maximum impact. They also need professional development to be hands-on or online/as needed and definitely need it to be time sensitive and focused.

On top of the need for hands-on and/or localized professional development, Montana is also the fourth largest state in the country and many communities are remote. MTDA saw the need for this localized (and hand-on whenever possible) professional development early on and created the regional ambassador program during the first year of operation. A team of four, part-time ambassadors currently team up to provide orientations, ongoing support, and a very successful regional professional development model to meet the needs of schools in a state that is over 500 miles by 300 miles in area!

Expanding EdReady Montana

The program, with the support of an expanding regional ambassador program to provide on-demand, hands-on, targeted, and individualized professional development, began to take off. It was quickly expanded to K-12 schools, adult education centers and other after school or alternative education programs all around Montana. EdReady Montana ambassadors and staff members presented to educators from around Montana at a variety of levels of education to find the best fit for their needs. Local educational leaders from both adult ed and K-12 recognized that EdReady Montana could help students upstream from their desired college or career pathway and well before they were faced with a college placement exam or turned away from a field due to gaps in math skills. Their use of the system to do that was the catalyst of growth for EdReady Montana. Best of all, the program individualized the instruction based upon each student’s need and contained learning resources specifically designed to speak to the college and career readiness level.

At the end of the first year, a team toured our state to interview educators and students to display the variety of ways our program impacted their programs, educators and students. Click here to watch that video:

Lessons Learned

Attaining solid funding for the program to remain free to Montanans has been an important aspect of the explosive growth and the wide array of organizations served. However, the program can be replicated elsewhere to impact large numbers of students in each of these educational levels or organizations, even without additional funding. There are several important lessons learned by MTDA that will help scale this program to other areas:

When using the program to impact student learning in a formal setting, find an educator or a team of educators who want to try something new and are not satisfied with some aspect of the way things currently work for them.

Make the student experience seamless and use similar techniques to make teacher/facilitator experience as easy as possible. We started by making the student experience: get a username, get a password, go to the website, log in and go. Everything else we did grew from there.

Find champions who will use the program early, and the rest will follow. Our phrase at MTDA is that we try to move users from “interest to implementation”.

You need to make data to have data. Start assessing and measuring early and use that information to make the program more effective over time.

You need hands-on professional development. We in Montana did this by building our regional ambassador program.

Technical support must be available and must be responsive. Nothing will kill an educational technology initiative quicker than a teacher sitting in front of a classroom full of non-functioning technology or students with accounts that do not work.

Define the roles and responsibilities of the group organizing the initiative and those applying it on the ground. Users of a reliable program must know what they need to do and what they can rely on others to do.

A healthy educational technology initiative program will evolve from technical training and support issues to teacher preparation and blended learning strategies. Once educators know what a technology program can do for them (and their students) they will start to innovate and adapt their practices around it to provide the best experience for their students.

In any online program, students cannot just click to learn math or be left abandoned on the system. Students who have missing concepts often also struggle with learning how to learn well. While the technology is essential to success, most students need more guidance and support from an educator both on and off the tool.

Educators need to take what is done in the system and make changes to their plans with their students. This completes the “blended learning loop” of preparing students to learn online but also using what they completed online to help inform instruction.

As can be the case in personalized learning programs like EdReady, the full effects may never fully be measured. Many of the students enter into a personal journey of improvement and are served individually by the program. The pervasive strength of the tool is how well the model works on an individual level. MTDA’s EdReady Montana program is a model for others to learn from and follow!

This video outlines the local support model and how the program works to meet and support the needs of local schools:

Are you interested in learning more about the EdReady Montana program or the model of scaling this sort of system to a large audience? If so, visit the links below or contact us using the information at the bottom of the page.

Ryan Schrenk, Ed.D, is the EdReady Program Manager at the Montana Digital Academy and has worked at MTDA since 2010. Prior to starting at MTDA he was a distance learning director at a 2-year college and taught in high school and middle school technology education programs. Since joining the Digital Academy, his work has focused on developing an online/modularized credit recovery program and is now leading the implementation of the EdReady Montana program. Phone: 406-203-1812. Email: ryan.schrenk@montanadigitalacademy.org

Robert Currie is the Executive Director of the Montana Digital Academy (MTDA) Montana’s statewide online program located at the University of Montana. Prior to starting MTDA he was the Executive Director of the Michigan Virtual School and was a superintendent and high school principal in Michigan. Currie is a founding member of the Virtual Learning Leadership Alliance, an organization consisting of fourteen state and regional virtual schools from across the U.S promoting collaboration in online learning. Phone: 406-203-1812. Email: robert.currie@montanadigitalacademy.org

]]>https://wcetfrontiers.org/2018/10/11/edready-montana/feed/0linsraedowns2018 WOW award logo. The WCET logo inside of a black box. Below the wcet logo, text reads "WOW award 2018." Underneath the black box reads "WCET Oustanding Work Award"An outline of the state of Montanalessons learned: Find educators who will try something new, Make the student experience seamless, Find champions to use the program early, Make data to have data, Offer hands-on professional development, Provide technical support, Define roles and responsibilities for all, Allow the program to evolve, Help students learn how to learn well, Complete the “blended learning loop.”ryan S. headshotRobert c. headshotCC Logo